Murphy v. Deloitte & Touche Group Insurance Plan

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that although district courts are prohibited from considering extra-record materials related to a claimant’s eligibility for benefits, they may consider “extra-record materials related to an administrator’s dual role conflict of interest”
• holding that all discovery, including discovery in ERISA matters, “is limited by Rule 26(b)(2), which protects against, inter alia, overly burdensome discovery requests, discovery of cumulative materials, and overly costly discovery requests”
• recognizing that benefit of allowing detailed discovery of administrator’s financial interest in ERISA claim “will often be outweighed by its burdens and costs because the inherent dual role conflict makes that financial interest obvious”
• stating that courts are prohibited from considering materials outside 5 . administrative record where the extra-record materials are related to a claimant’s eligibility for benefits
• explaining that Tenth Circuit’s “broad language prohibiting extra-record discovery is potentially misleading in cases involving a dual role conflict of interests or procedural irregularities”
• explaining that Rule 26(b) governs dual conflict of interest discovery requests and “other” discovery requests in ERISA cases

Source: CourtListener parenthetical corpus (CC0).